A Little Spooky and Its Not Even Halloween: Idiotic Compliance Advice and the London Olympics

One of the joys of being a co-host in This Week in FCPA is getting to see and hear my partner, Howard Sklar, go on rants. Sometimes they are planned and sometimes not. Episode 45 had one of the latter as I really do not think that Howard planned to go on about Orthofix but he did. When he finished all I could say was “Wow, I didn’t see that coming.” So go view Episode 45 on either the Blogsite or simply listen to it on iTunes and enjoy it.

Howard does not just leave the rants to the audio-video sector of his burgeoning media empire, which I would note for the record is not owned by News Corp. Today he treated us to an online rant in his blog post entitled “The Limit Should Be Zero Dollars”. He was commenting upon a blog post entitled “Inside Straight: The Shoemaker’s Children” by my fellow UM-Law classmate Mark Hermann about some advice that Mark received from an un-named lawyer from an un-named law firm about gift-giving under the UK Bribery Act. This un-named lawyer’s advice was that to meet the requirements of the UK Bribery Act, a company’s gift giving policy should be zero dollars, as in no gifts allowed. So this lawyer went to the ‘idiot box’ in Howard’s head. A scary place to be, indeed.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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